Privacy Policy

Who we are

ICP Group is an international group of companies that operates in multiple jurisdictions around the world, offering a range of specialty coatings, adhesives and sealants. This Notice is provided for and on behalf of each data controller within our group which includes the legal entities listed here https://www.icpgroup.com/terms/.

Comments

The Innovative Chemical Products Group (ICP Group, we, us, our) respects privacy and is committed to protecting personal information. We have developed this Privacy Notice to inform all our customers, business partners, suppliers, service providers and other third parties that we interact with in the course of providing our products and services, as well as our website users whose information we collect as a result of navigating or interacting with us through the site (collectively you, your), about how we collect and use personal information.

Important information about this Notice

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to update this Notice from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your personal information. Please note that this Privacy Notice supplements the other notices and is not intended to override them. To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Notice for updates. We also ask that where we have an ongoing relationship with you and any of the data you have provided become are no longer accurate you keep us informed of this so that we can amend our records accordingly. We do not provide products or services to children and do not knowingly collect or otherwise process the personal information of legal minors. Accordingly and to assist us with this, we ask that you do not submit any information to us that relates to minors

Cookies

If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

What personal information do we collect about you & how do we collect it?

Personal information includes any information about you that can be used to contact or identify you. It does not however include data which has been permanently anonymized to prevent identification or aggregated statistical data which we may generate to monitor the performance of our business and to help improve our service and product offering. When using our website, communicating with us regarding our products and services or otherwise interacting with us in the context of our business, then we may collect, use, store and otherwise process the following categories of personal information:
ICP Group (Website Privacy Notice)
 Identity Data: this may include first name last name.
 Contact Data: this may include your email address and telephone number. Where you represent or otherwise act on behalf of one of our corporate customers, then this may also include the identity of your employer, your position/role and geographical location of employment.
 Transaction Data: this may include financial institution, bank account and payment card details. It may also include details about payments to and from you and other details of your purchasing history.
 Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
 Usage Data: includes information about how you use our website.
 Marketing Data: includes your preferences in relation to receiving marketing communications from us.

What if you fail to provide the personal information requested?

There may be cases where we need certain information in order to enter into a contract with you or, where we already have such a relationship with you, to administer the terms of the contract. In such cases, where you fail to provide that information requested, then we may not be able to enter into that contract with you, or may be prevented from performing aspects of it (including but not limited to providing you with goods or services). In those circumstances, we may have to cancel a product or service you have with us, but we will always notify you if this is the case at the time.

On what basis do we use your personal information?

We will use your personal data in the following circumstances:
 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
 Where necessary to enter into or perform an existing a contract with you.
 Where we need to comply with a legal or regulatory obligation.
 In rare cases, on the basis that you have provided your consent.
In the limited circumstances that we rely on your consent in order to process your personal data, we will only do so where your consent is clear, unambiguous and informed. In addition, you can withdraw your consent at any time, although please note that withdrawal of your consent would not affect the legality of any processing which has already occurred.

For what purposes will we use your personal information?

We will process different types of information for different purposes depending on the nature of the information and your relationship with us. We have created the table below in order to provide a description of all the ways we plan to use your personal information and our basis for doing so. Where we process your information on the basis of our legitimate interests then we have also identified what those interests are. Please note that we may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.

Purpose/ Activity Type of Information Basis of Processing
To enter into and subsequently to manage our business relationship with you,
including:
 Negotiating and concluding agreements for products or services
 Responding to product or service related enquiries and providing client support
 Managing and processing transactions in relation to the provision of goods or services
 Managing and processing the shipment of orders, delivery and returns
 Notifying you about changes to our terms of business or privacy notice
 Identity Data
 Contact Data
 Transaction Data
 Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records)
 Performance of a contract with you
 Necessary to comply with legal obligations
To administer and protect our business and website including:
 Maintaining business records for legal purposes and to comply with tax requirements
 Defending and advancing legal claims
 Ensuring effective website maintenance and security
 Identity Data
 Contact Data
 Technical Data
 Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
 Necessary to comply with legal obligations
To make decisions about how best to deliver relevant website content and advertisements to you, and to better understand their effectiveness
 Technical Data
 Usage Data
 Marketing Data
Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site)
To advance and promote our business including contacting you regarding products, services or promotions that may be of interest to you based on products or services you have previously obtained from us, and to enable reviews and surveys
 Identity Data
 Contact Data
 Transaction Data
 Marketing Data
Necessary for our legitimate interests (to enhance our products and services, improve our marketing strategies and develop our business)

How do we use your personal data for marketing?

We may send you direct marketing communications from time to time including news, updates, offers and other promotions relating to our products, services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of thecommunication you have received or by contacting us using the information provided below. We will never sell your information to third party data brokers or marketing companies.

Will we share your information with others?

Sometimes it may be necessary to share your personal data with trusted third parties, including:
 Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information only to perform specific tasks on our behalf and are obliged not to disclose or use it for any other purpose. Our service providers include (i) IT and system administration providers (ii) marketing and advertising agencies; (iii) logistics and delivery agents; (iv) data analytics providers and (v) payment institutions that we use to process payments.
 Regulatory and governmental authorities, law enforcement agencies and courts.
 Our professional advisors.
 Other entities within our group of companies.
 In the event of a disposal of all or part of our business, the purchaser and its professional advisors.

How do we ensure the security of your personal information?

We have implemented appropriate technical and organizational measures to protect your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and service providers who have a business need to know. They will only process your information on our instructions and are subject to a formal duty of confidentiality. Any third parties involved in handling your
personal information will only do so for specific purposes and will be subject to contractual obligations of confidentiality. In the event that we experience any intrusion of our information systems or otherwise suffer a breach of our data security, then the Group has in place specific procedures designed to deal with such a breach, including protecting the personal information within our control and, where we are legally obliged to do so, notifying you and the relevant authorities. Please note however that despite our best efforts we cannot guarantee the security of information being exchanged over the internet
and, where our website contains links to other sites plug-ins and applications that are not operated by us, clicking on those links or enabling those connections may allow third parties to collect or share data about you. Once you leave our website then we have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services.

How long will we keep your personal information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means and the applicable legal requirements. To the extent data is held in connection with contractual rights and obligations, then we will also take into account any specific limitation periods that apply under local law.

GDPR

Due to the international nature of the ICP Group and its business we have affiliates located in the UK and the EU. We take our responsibilities under the GDPR seriously and have included this additional section in our Notice for individuals located in these jurisdictions.

1) Will we transfer your personal information internationally?
As an international organization sometimes we may need to transfer your personal data overseas, including to destinations outside the UK and the European Economic Area (EEA). However, we will only transfer your data to another country where we are confident that an appropriate degree of protection will be provided. In particular, we will only transfer your personal data to countries that have either been deemed to provide an adequate level of protection for personal data, or where there are specific contractual clauses in place to protect the transfer of your data. For more information about how we use approved Standard Contractual Clauses, please contact us using the details provided below.

2) What are your legal rights in connection with your personal information?
Under the GDPR you have certain rights in relation to your data which are listed below. However, please note that not all of these apply in all circumstances:
 Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. However, please note that if you are requesting access to your data then in order to protect the rights of others we may require you to validate your identity before we can release that information to you
 Right to rectify your personal information: if you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected).  Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is notabsolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoingcontractual relationship or are required to retain information to comply with our legal obligations.
 Right to restriction of processing: in some cases you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until theaccuracy is verified.
 Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
 Right to data portability: you have the right to receive, move, copy or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
In the event that you wish to exercise any of the rights identified above, then please get in touch using the contact details provided below.

3) Questions or complaints?
If you have any questions regarding the ways in which we process your personal data, then you can always contact us using the contact information provided below.
You also have the right to make a complaint at any time to the relevant supervisory authority in your jurisdiction. Details of relevant national data protection authorities are provided in the Schedule to this Notice.
Contact Us
If you have any questions about this Privacy Notice or about how we handle your personal information, then please write to us either by email to privacy@icpgroup.com or at the following address:
Attn: HR Director
ICP Group
150 Dascomb Road
Andover, MA 01810
United States of America

NATIONAL DATA PROTECTION AUTHORITIES

UNITED KINGDOM
The Information Commissioner’s Office
Tel: +44 303 123 1113
Website: https://ico.org.uk/global/privacy-notice/making-a-complaint/

EUROPEAN UNION (EU)

Austria
Österreichische Datenschutzbehörde
Barichgasse 40-42, 1030 Wien
Website: http://www.dsb.gv.at/
Tel. +43 1 52152 2550
Email: dsb@dsb.gv.at
Website: http://www.dsb.gv.at/

Belgium
Autorité de la protection des données – Gegevensbeschermingsautoriteit (APD-GBA)
Rue de la Presse 35, Drukpersstraat 35, 1000 Bruxelles, Brussel
Tel. +32 2 274 48 00
Email: contact@apd-gba.be
Website: https://www.autoriteprotectiondonnees.be/
https://www.gegevensbeschermingsautoriteit.be/

Bulgaria
Commission for Personal Data Protection
2, Prof. Tsvetan Lazarov blvd. Sofia 1592
Tel. + 359 2 915 3580
Fax +359 2 915 3525
email: kzld@cpdp.bg
Website: https://www.cpdp.bg/
Croatia
Croatian Personal Data Protection Agency
Selska Cesta 136, 10000 Zagreb
Tel. +385 1 4609 000
Fax +385 1 4609 099 email: azop@azop.hr
Website: http://www.azop.hr/

Cyprus
Commissioner for Personal Data Protection
1 Iasonos Street, 1082 Nicosia, P.O. Box 23378, CY-1682 Nicosia
Tel. +357 22 818 456
Fax +357 22 304 565
email: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy/

Czech Republic
Office for Personal Data Protection
Pplk. Sochora 27, 170 00 Prague 7
Tel. +420 234 665 111
Fax +420 234 665 444
email: posta@uoou.cz
Website: http://www.uoou.cz/

Denmark
Datatilsynet
Carl Jacobsens Vej 35, 2500 Valby
Tel. +45 33 1932 00
Fax +45 33 19 32 18
email: dt@datatilsynet.dk
Website: http://www.datatilsynet.dk/

Estonia
Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Tatari 39, 10134 Tallinn
Tel. +372 6828 712 email: info@aki.ee
Website: http://www.aki.ee/

European Data Protection Supervisor
Rue Wiertz 60, 1047 Bruxelles/Brussel
Rue Montoyer 30, 6th floor
Tel. +32 2 283 19 00
Fax +32 2 283 19 50
Email: edps@edps.europa.eu
Website: http://www.edps.europa.eu/EDPSWEB/

Finland
Office of the Data Protection Ombudsman
P.O. Box 800, FI-00531 Helsinki
Tel. +358 29 56 66700
Fax +358 29 56 66735
Email: tietosuoja@om.fi
Website: http://www.tietosuoja.fi/en/

France
Commission Nationale de l’Informatique et des Libertés – CNIL
3 Place de Fontenoy, TSA 80715 – 75334 Paris, Cedex 07
Tel. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
Contact: https://www.cnil.fr/en/contact-cnil
Website: http://www.cnil.fr/

Germany
Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit, Graurheindorfer
Straße 153, 53117 Bonn
Tel.: +49 228 997799 0 Fax: +49 228 997799 5550
email: poststelle@bfdi.bund.de
Website: http://www.bfdi.bund.de/
Competent authorities can be identified according to the list provided under www.bfdi.bund.de/anschriften

Greece
Hellenic Data Protection Authority
Kifisias Av. 1-3, PC 11523, Ampelokipi Athens
Tel. +30 210 6475 600
Fax +30 210 6475 628
email: contact@dpa.gr
Website: http://www.dpa.gr/

Hungary
Hungarian National Authority for Data Protection and Freedom of Information
Szilágyi Erzsébet fasor 22/C
H-1125 Budapest
Tel. +36 1 3911 400
email: privacy@naih.hu
Website: http://www.naih.hu/

Ireland
Data Protection Commission
21 Fitzwilliam Square, Dublin 2
D02 RD28
Ireland
Tel. +353 76 110 4800
email: info@dataprotection.ie
Website: http://www.dataprotection.ie/

Italy Garante per la protezione dei dati personali
Piazza Venezia, 11, 00187 Roma
Tel. +39 06 69677 1
Fax +39 06 69677 785
email: protocollo@gpdp.it
Website: http://www.garanteprivacy.it/

Latvia
Data State Inspectorate
Blaumana str. 11/13-15, 1011 Riga
Tel. +371 6722 3131
Fax +371 6722 3556
email: info@dvi.gov.lv
Website: http://www.dvi.gov.lv/

Lithuania
State Data Protection Inspectorate
L Sapiegos str. 17, LT-10312 Vilnius
Tel. +370 5 271 2804 / +370 5 279 1445
Fax +370 5 261 9494
email: ada@ada.lt
Website: http://www.ada.lt/

Luxembourg
Commission Nationale pour la Protection des Données
15, Boulevard du Jazz,L-4370 Belvaux
Tel. +352 2610 60 1
Fax +352 2610 60 6099
email: info@cnpd.lu
Website: http://www.cnpd.lu/

Malta
Office of the Information and Data Protection Commissioner
Second Floor, Airways House, High Street, Sliema SLM 1549
Tel. +356 2328 7100
Fax +356 2328 7198
email: idpc.info@idpc.org.mt
Website: http://www.idpc.org.mt/

Netherlands
Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30
P.O. Box 93374,2509 AJ Den Haag/The Hague
Tel. +31 70 888 8500
Fax +31 70 888 8501
Website: https://autoriteitpersoonsgegevens.nl/nl

Poland Urząd Ochrony Danych Osobowych (Personal Data Protection Office)
ul. Stawki 2, 00-193 Warsaw
Tel. +48 22 531 03 00
Fax +48 22 531 03 01
email: kancelaria@uodo.gov.pl; zwme@uodo.gov.pl
Website: https://uodo.gov.pl/

Portugal
Comissão Nacional de Protecção de Dados – CNPD
Av. D. Carlos I, 134, 1º, 1200-651 Lisboa
Tel. +351 21 392 84 00
Fax +351 21 397 68 32
email: geral@cnpd.pt Website: http://www.cnpd.pt/

Romania
The National Supervisory Authority for Personal Data Processing
B-dul Magheru 28-30, Sector 1, BUCUREŞTI
Tel. +40 31 805 9211
Fax +40 31 805 9602
email: anspdcp@dataprotection.ro
Website: http://www.dataprotection.ro/

Slovakia
Office for Personal Data Protection of the Slovak Republic
Hraničná 12, 820 07 Bratislava 27
Tel.: + 421 2 32 31 32 14
Fax: + 421 2 32 31 32 34
email: statny.dozor@pdp.gov.sk
Website: http://www.dataprotection.gov.sk/

Slovenia
Information Commissioner of the Republic of Slovenia
Dunajska 22, 1000 Ljubljana
Tel. +386 1 230 9730
Fax +386 1 230 9778
email: gp.ip@ip-rs.si
Website: https://www.ip-rs.si/

Spain
Agencia Española de Protección de Datos (AEPD)
C/Jorge Juan, 6, 28001 Madrid
Tel. +34 91 266 3517
Fax +34 91 455 5699 Email: internacional@aepd.es
Website: https://www.aepd.es/

Sweden
Datainspektionen
Drottninggatan 29, 5th Floor, Box 8114, 104 20 Stockholm
Tel. +46 8 657 6100
Fax +46 8 652 8652
Email: datainspektionen@datainspektionen.se
Website: http://www.datainspektionen.se/

EUROPEAN FREE TRADE AREA (EFTA)

Iceland
Persónuvernd
Rauðarárstígur 10, 105 Reykjavík
Tel: +354 510 9600
email: postur@dpa.is
Website: https://www.personuvernd.is or https://www.dpa.is
Ms Helga Þórisdóttir, Commissioner

Liechtenstein Data Protection Authority, Principality of Liechtenstein
Städtle 38, 9490 Vaduz, Principality of Liechtenstein
Tel. +423 236 6090
Email: info.dss@llv.li
Website: https://www.datenschutzstelle.li

Norway
Datatilsynet
Tollbugata 3, 0152 Oslo
Tel +47 22 39 69 00 Email: postkasse@datatilsynet.no
Website: www.datatilsynet.no
Switzerland
Data Protection and Information Commissioner of Switzerland
Website: https://www.edoeb.admin.ch/edoeb/de/home.html